by Lynam Knott | Jan 14, 2014 | Aggressive Tax Positions, Taxpayer Underpayment, Uncertain Tax Positions, Whistleblower Awards
Today’s CFO Journal reported that a warning from the Public Company Accounting Oversight Board (“PCAOB”) late last year has resulted in much more stringent external audits being conducted by auditors of public companies. PCAOB has been...
by Lynam Knott | Nov 6, 2013 | Aggressive Tax Positions, Criminal Fines, Department of Justice, Taxpayer Underpayment
Tax shelters are an on-going battle for the IRS and the Department of Justice with large amounts of money at stake for the government, the taxpayer, and possibly for a knowledgeable whistleblower. Tax shelter cases involve schemes that attempt to manipulate...
by Lynam Knott | Oct 28, 2013 | Aggressive Tax Positions, Offshore Assets, Taxpayer Underpayment, Uncertain Tax Positions
Kudos to Martin Sullivan, Chief Economist and Contributing Editor at Tax Analysts who had a nice piece in the Washington Post published about him over the weekend. I’ve always admired Marty’s ability to cut through the political BS and revenue...
by Lynam Knott | Mar 26, 2013 | Aggressive Tax Positions, Offshore Assets, Taxpayer Underpayment, Uncertain Tax Positions
I saw an interesting article today by the President and Publisher of Tax Analysts in which he drew attention to the role of tax professionals in the growing crisis over reduced corporate tax receipts in a time of record corporate profits. He focused his...
by Lynam Knott | Dec 18, 2012 | Aggressive Tax Positions, Department of Justice, Offshore Assets
Tax practitioners and government officials recently came together at the American Bar Association International Tax Enforcement Conference in New York to discuss international tax enforcement rules and procedures. Among the topics of discussion was the federal...
by Lynam Knott | Sep 10, 2012 | Aggressive Tax Positions, Uncertain Tax Positions
Today we released our 2012 “Ferraro 500” list, which reorders Fortune 500 companies based on the size of their Unrecognized Tax Benefit reserves. This annual study always has some interesting results and outliers. For example, Fortune 500 corporate profits...
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